Comment on Upcoming NAEP Civics Assessment Framework Update

National Association of Scholars

Editor’s Note: The National Association of Scholars (NAS) and the Civics Alliance work to ensure that every state has academic standards that promote first-rate education and protect school children from political indoctrination. We promote reform of content standards in every state, along the lines modeled by the Civics Alliance’s American Birthright: The Civics Alliance’s Model K-12 Social Studies Standards. We believe that the NAEP Civics Assessment Framework (NAEP-CAF) needs to be updated, above all to refocus upon essential civics knowledge and to remove alignments with politicized material, including “action civics.” We urge the NAGB to undertake a series of reforms to improve the NAEP-CAF.

The following letter was sent to Lesley Muldoon, Executive Director of the National Assessment Governing Board. 


Lesley Muldoon, Executive Director
National Assessment Governing Board (NAGB)
U.S. Department of Education
400 Maryland Ave. SW
Washington, DC 20202
Mailstop: 1A112D
nagb@ed.gov

March 3, 2026

Dear Executive Director Muldoon,

The National Assessment Governing Board (NAGB) has asked for public comment prior to updating the Civics Assessment Framework for the National Assessment of Educational Progress (NAEP).1 It has asked specifically for comments to address three questions:

  • Does the NAEP Civics Assessment Framework need to be updated?
  • If the framework needs to be updated, why is a revision needed?
  • What should a revision to the framework include?

The National Association of Scholars (NAS) and the Civics Alliance do believe that the NAEP Civics Assessment Framework (NAEP-CAF) needs to be updated, above all to refocus upon essential civics knowledge and to remove alignments with politicized material, including “action civics.” We urge the NAGB to undertake a series of reforms to improve the NAEP-CAF.

NAEP-CAF Shortcomings

The existing NAEP-CAF has been politicized, above all by aligning with “action civics”—vocational training in progressive activism that replaces classroom civics education.2 The NAEP-CAF currently measures student knowledge of intellectual skills, participatory skills, civic dispositions, and civic skills. All these phrases serve as euphemisms for action civics. NAEP-CAF also reveals politicization by radicalized language, such as:

  • referring to America as a constitutional democracy or a democracy rather than as a republic, and
  • referring to patriotic language and symbols by the dismissive adjective emotional.

The NAEP-CAF should be updated to remove all politicized language and all alignment with politicized pedagogy.

The NAEP-CAF also lacks essential civics focus. Civics education should include, as primary categories, knowledge of our foundational documents of liberty (e.g., the Declaration of Independence, the Constitution), as well as of their intellectual sources. It also should focus upon America’s constitutional history. The NAEP-CAF should be updated to add these as primary categories of testable knowledge.

The NAEP-CAF also should be reformed to provide assessable rigor. The NAEP-CAF has been reduced from tests in Grade 4, Grade 8, and Grade 11 to just one test at Grade 8. That one test is not done at a scale large enough to allow for state-level disaggregation. The NAEP-CAF’s baseline for proficiency also may have been substantially degraded, because it does not provide large enough samples of classical school students and home school students—whose civics facility would provide a useful baseline for proficiency.

Revision Recommendations

Do Not Use AIR as a Contractor: The NAGB should not entrust updating the NAEP-CAF to the American Institutes for Research (AIR). Organizations that hire AIR to take part in their social studies and civics work standardly produce products3 that recapitulate the flaws of the National Council for the Social Studies’ (NCSS) ideologically extremedefinition of social studies,4 and of its College, Career, and Civic Life (C3) Framework for Social Studies State Standards, which replaces content knowledge with insubstantial and opaque “inquiry”; replaces social studies pedagogy with identity politics ideologies such as Critical Race Theory; and inserts ideologically extreme pedagogies such as Action Civics.5 A decision to hire AIR is tantamount to a decision to adopt the ideologically extreme structure of the NCSS’ C3 Framework. The NAGB should not hire AIR, or in any way involve AIR, in any part of the creation or revision of the NAEP-CAF.6

Consider an Alternate Contracting Consortium: The existing Civics Assessment Framework was jointly drafted by the Council of Chief State School Officers with the Center for Civic Education and the American Institutes for Research. The NAGB should consider an alternate contracting consortium, consisting (for example) of Classic Learning Initiatives, the Core Knowledge Foundation, the Hamilton School for Classical and Civic Education at the University of Florida, and Hillsdale College.

Align with Alternate Standards: The NAEP-CAF now boasts of its consistency with the Center for Civic Education’s National Standards for Civics and Government. The NAGB should direct a new contractor to align the NAEP-CAF with better standards, such as The Hillsdale College K-12 History & Civics Curriculum,7 Foundations of Freedom: Louisiana High School Civics,8 and American Birthright: The Civics Alliance’s Model K-12 Social Studies Standards.9

Consider Aligning with the U.S. Civics Test: 25 states now align their K-12 civics instruction with the U.S. Civics testgiven to immigrants who wish to be naturalized. The NAGB should consider aligning tested content with the content of the U.S. Civics Test—specifically, the existing (2026) 128-question civics test.

Strengthen Testing Scope: The NAGB should request sufficient resources to allow it to restore tests for the 4th grade, the 8th grade, and the 11th grade, rather than simply retaining the 8th grade test. It should increase the frequency of the tests to be every two years. It also should increase the number of tested students to allow for significant sample sizes from 1) each state; 2) from classical school students; and 3) from home school students. The NAGB should oversample students from smaller states, classical schools, and home schools, to ensure that it has sufficient sample sizes.

Strengthen Testing Rigor: NAGB should establish rigorous baselines for proficiency. It should do so not least by examining its classical school and home school samples to establish a properly rigorous baseline for proficiency. NAGB also should use computerized assessments to seek out and grade for especially advanced proficiency. Computer technology now allows assessments to determine fine gradations among elite performers. NAGB should determine in granular detail the elite performers on the NAEP-CAF, not least to provide useful material for civics-focused scholarship and grant programs.

Remove Questions on Participatory Skills and Civic Dispositions: The current NAEP-CAF devotes 10-15% of questions to “students’ knowledge and understanding of participatory skills”, and another 10-15% to “questions related to civic dispositions”.10 The NAGB should remove these categories and these questions entirely from the NAEP-CAF. To do so, NAGB should focus on reducing the content assigned to the question category “What are the roles of citizens in American democracy?”

Remove Inquiry Format: The current NAEP-CAF uses an “inquiry-based” format even to categorize Civic Knowledge, framing it in terms of five questions.11 These should be rephrased as five content knowledge categories—identifying categories of knowledge, not questions. The careful distribution of questions by Intellectual Skills likewise reflects education-school fussiness rather than an essential category for the NAEP-CAF.12 NAGB should consider whether to eliminate these requirements, if they get in the way of drafting a sensible test by subject matter.

Add Categories on Primary Sources, Intellectual Influences, and Constitutional History: The current NAEP-CAF devotes 25% of Grade 8 questions to “What are the foundations of the American political system?”13 This category should be increased to three categories, including America’s Foundational Documents of Liberty, Intellectual Sources for America’s Foundational Documents of Liberty (including the Bible and Protestant political theory, Greco-Roman political thought, English law, the Enlightenment, and colonial American ideas and practice), and Constitutional History. These categories should be framed to generate questions that assess students’ familiarity with and ability to analyze the foundational primary sources of America’s civic inheritance. The portions of the NAEP-CAF currently assigned to Participatory Skills and Civic Dispositions should be reassigned to these categories.

Confine Text-based Stimulus Materials to Historical Examples: The current NAEP-CAF now allows text-based stimulus materials to include contemporary documents. This allows questions that align with action civics: “For example, students may be asked to take a position regarding a community planning issue after examining a map and reading about the proposed change.”14 Text-based stimulus materials only should include historical documents, which allow no prompts for action civics.

Reform Civic Participation Category: The current category “What are the roles of citizens in American democracy?” focuses excessively on how citizens should influence government or hold government to account. While this matters, it underplays tests on how citizens can participate in government—as aldermen and mayors, as school board members and judges, as jurors and members of the National Guard, as policemen, firemen, and members of the Border Patrol. At least half the questions in this category should focus on different forms of civic participation in government. This category also should include questions on civil society, including assessment of knowledge of Robert’s Rules of Order.

Depoliticize Throughout: The NAGB should ensure that the NAEP-CAF includes no politicized language or content. For example:

  • Refer to the United States exclusively as a republic, never as a constitutional democracy or a democracy.
  • Refer to patriotic language and symbols, not emotional language and symbols.
  • Include no material that aligns with action civics, including service-learning. Carefully inspect language referring to volunteering, building coalitions, advocating, deliberating on public issues, holding public officials accountable, petitioning, and participating in civic and advocacy groups, to see if it euphemizes action civics.
  • Seek the best civics education rather than a “broad consensus,” since the “broad consensus” now includes dedicated proponents of politicizing civics education.
  • Define equality exclusively as equality of opportunity, so as to avoid giving countenance to the oppressive ideology of equity.
  • Craft the NAEP-CAF without worrying about bias or contextual information, since these frequently serve as euphemisms for politicized content and pedagogy.

Conclusion

NAS and the Civics Alliance believe that these reforms would greatly strengthen the NAEP-CAF. We strongly urge the NAGB to undertake them.

Respectfully yours,

Peter Wood 
President, National Association of Scholars

David Randall
Executive Director, Civics Alliance


1 Civics Framework for the 2018 National Assessment of Educational Progress (National Assessment Governing Board, U.S. Department of Education), https://www.nagb.gov/content/dam/nagb/en/documents/publications/frameworks/civics/2018-civics-framework.pdf.

2 Stanley Kurtz, “‘Action Civics’ Replaces Citizenship with Partisanship,” The American Mind, January 16, 2021, https://americanmind.org/memo/action-civics-replaces-citizenship-with-partisanship/; Thomas K. Lindsay and Lucy Meckler, “Action Civics,” “New Civics,” “Civic Engagement,” and “Project-Based Civics”: Advances in Civic Education? (Texas Public Policy Foundation, 2020), https://www.texaspolicy.com/wp-content/uploads/2020/09/Lindsay-Meckler-Action-Civics.pdf.

3 E.g., Alaska Social Studies Standards (2024), Department of Education and Early Development, https://education.alaska.gov/akstandards/Adopted-AK-SS-Standards-2024.pdf. “Alaska completed our RFP process and we received one vendor application for the facilitator. American Institutes for Research (AIR) was the selected vendor.” Kelly Manning (Deputy Director) to David Randall, March 31, 2023.

4 Comment on the NCSS’s New “Social Studies” Definition, Civics Alliance, https://civicsalliance.org/comment-on-the-ncsss-new-social-studies-definition/.

5 David Randall, Issue Brief: The C3 Framework, National Association of Scholars,
https://www.nas.org/blogs/article/issue-brief-the-c3-framework; Stanley Kurtz, “Consensus by
Surrender,” National Review, June 10, 2021, https://www.nationalreview.com/corner/consensusby-surrender/.

6 Furthermore, journalists recently have published evidence that AIR has overcharged the federal government for its work as a contractor. Alex Gutentag and Michael Shellenberger, “US Education Department Contractor Overcharged Taxpayers While Spending Millions On Executive Salaries,” Public, March 17, 2025, https://www.public.news/p/us-education-department-contractor. Prudence suggests that the NAGB should investigate whether AIR has overcharged it for its previous work, and hesitate before contracting with it again.

7 The Hillsdale College K-12 History & Civics Curriculum, Hillsdale College, https://k12.hillsdale.edu/Curriculum/Hillsdale-K12-American-History/.

8 Foundations of Freedom: Louisiana High School Civics, Louisiana Department of Education and Core Knowledge Foundation, https://www.coreknowledge.org/louisiana-foundations-of-freedom/.

9 American Birthright: The Civics Alliance’s Model K-12 Social Studies Standards, Civics Alliance, https://civicsalliance.org/american-birthright/.

10 Civics Framework for the 2018 National Assessment of Educational Progress, p. 43.

11 Civics Framework for the 2018 National Assessment of Educational Progress, p. 41.

12 Civics Framework for the 2018 National Assessment of Educational Progress, p. 42.

13 Civics Framework for the 2018 National Assessment of Educational Progress, p. 41.

14 Civics Framework for the 2018 National Assessment of Educational Progress, p. 46.


Photo by Vitaly Gariev on Unsplash

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